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Linkhome Holdings Inc.
Response Received
11 company response(s)
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Linkhome Holdings Inc.
Response Received
1 company response(s)
Medium - date proximity
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Linkhome Holdings Inc.
Awaiting Response
0 company response(s)
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Linkhome Holdings Inc.
Awaiting Response
0 company response(s)
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Linkhome Holdings Inc.
Awaiting Response
0 company response(s)
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SEC wrote to company
2024-10-16
Linkhome Holdings Inc.
Summary
Generating summary...
Linkhome Holdings Inc.
Awaiting Response
0 company response(s)
High
SEC wrote to company
2024-07-19
Linkhome Holdings Inc.
Summary
Generating summary...
Linkhome Holdings Inc.
Response Received
1 company response(s)
Medium - date proximity
SEC wrote to company
2024-06-11
Linkhome Holdings Inc.
Summary
Generating summary...
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Company responded
2024-06-21
Linkhome Holdings Inc.
Summary
Generating summary...
Summary
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-07-22 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-07-22 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-07-18 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-07-17 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 333-280379 | Read Filing View |
| 2025-05-13 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-05-13 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-04-02 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-03-28 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 333-280379 | Read Filing View |
| 2025-03-24 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-02-04 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 333-280379 | Read Filing View |
| 2024-11-07 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-11-07 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-10-17 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-10-16 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| 2024-07-19 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-07-19 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| 2024-07-10 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-07-03 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| 2024-06-21 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-06-11 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-07-17 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 333-280379 | Read Filing View |
| 2025-03-28 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 333-280379 | Read Filing View |
| 2025-02-04 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 333-280379 | Read Filing View |
| 2024-10-16 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| 2024-07-19 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| 2024-07-03 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| 2024-06-11 | SEC Comment Letter | Linkhome Holdings Inc. | NV | 377-07179 | Read Filing View |
| Date | Type | Company | Location | File No | Link |
|---|---|---|---|---|---|
| 2025-07-22 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-07-22 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-07-18 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-05-13 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-05-13 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-04-02 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2025-03-24 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-11-07 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-11-07 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-10-17 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-07-19 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-07-10 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
| 2024-06-21 | Company Response | Linkhome Holdings Inc. | NV | N/A | Read Filing View |
2025-07-22 - CORRESP - Linkhome Holdings Inc.
CORRESP 1 filename1.htm US Tiger Securities, Inc. 437 Madison Ave., 27th Floor New York, NY 10022 July 22, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Trade & Services 100 F Street, NE Washington, D.C., 20549 Attn: Pearlyne Paulemon and Pam Howell Re: Linkhome Holdings Inc. Post Effective Amendment No. 6 Registration Statement on Form S-1, as amended Filed on July 18, 2025 File No. 333-280379 Dear Ms. Paulemon and Ms. Pam Howell, Pursuant to Rule 461 under the Securities Act of 1933, as amended (the "Act"), the undersigned, for itself and the other underwriters, hereby join in the request by Linkhome Holdings Inc. that the effective date of the above-referenced registration statement be accelerated so that it will be declared effective at 4:00 p.m. Eastern Time on July 23, 2025, or as soon thereafter as is practicable. Pursuant to Rule 460 under the Act, we wish to advise you that the underwriters will distribute as many copies of the preliminary prospectus to underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution. The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 promulgated under the Securities Exchange Act of 1934, as amended. Very Truly Yours, US Tiger Securities, Inc. By: /s/ Jack Ye Name: Jack Ye Title: Managing Director cc: Fang Liu, Esq. of VCL Law LLP
2025-07-22 - CORRESP - Linkhome Holdings Inc.
CORRESP 1 filename1.htm Linkhome Holdings Inc. 2 Executive Circle, Suite 100 Irvine, CA 92614 July 22, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, D.C. 20549 Attention: Pearlyne Paulemon and Pam Howell RE: Linkhome Holdings Inc. Post Effective Amendment No. 6 Registration Statement on Form S-1, as amended Filed on July 18, 2025 File No. 333- 280379 Dear Ms. Paulemon and Ms. Pam Howell, Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, as amended, Linkhome Holdings Inc. respectfully requests that the effective date of the above-referenced Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m. Washington D.C. time on July 23, 2025, or as soon thereafter as practicable. Please call Michael Blankenship of Winston & Strawn LLP at (713) 651-2678 to provide notice of the effectiveness of the Registration Statement. [ Signature Page Follows ] Very truly yours, Linkhome Holdings Inc. By: /S/ Zhen "Bill" Qin Name: Zhen "Bill" Qin Tite: Chief Executive Officer cc: Michael Blankenship, Winston & Strawn LLP
2025-07-18 - CORRESP - Linkhome Holdings Inc.
CORRESP 1 filename1.htm July 18, 2025 BY EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, NE Washington, DC 20549 Re: Linkhome Holdings Inc. Post-Effective Amendment No. 5 to Registration Statement on Form S-1 Filed June 26, 2025 File No. 333-280379 Ladies and Gentlemen: On behalf of our client, Linkhome Holdings Inc. (the " Company "), we are writing to submit the Company's response to the comments of the staff (the " Staff ") of the Division of Corporation Finance of the United States Securities and Exchange Commission (the " Commission ") set forth in its letter, dated July 17, 2025, relating to the Company's Post-Effective Amendment No. 5 to Registration Statement on Form S-1 filed via EDGAR on June 26, 2025. The Company is concurrently filing via EDGAR the Post-Effective Amendment No. 6 to Registration Statement on Form S-1 (the " Registration Statement "), which reflects the Company's response to the comments received by the Staff and certain updated information. We have set forth below the comments in the Staff's letter, in bold, and the Company's responses thereto. Post-Effective Amendment No.5 on Form S-1 filed June 26, 2025 Certain Relationships and Related Party Transactions, page 80 1. Please update to provide the disclosure required by Item 404 of Regulation S-K for the three months ended March 31, 2025. Response : The Company acknowledges the Staff's comment and has revised pages 80 and 81 of the Registration Statement to address the Staff's comment. Underwriting, page 92 2. We note that this offering relates to 1,250,000 shares of your common stock. We also note your disclosure here, that the underwriters are committed to purchase 2,000,000 shares. Please revise for consistency or advise. Response : The Company acknowledges the Staff's comment and has revised page 92 of the Registration Statement to address the Staff's comment. General 3. We note that Exhibit 5.1 refers to underwriter warrants that are not present in the prospectus. Please revise your legal opinion to opine on the securities being offered or advise. Response : The Company acknowledges the Staff's comment and has removed the previously filed Exhibit 5.1. * * * * * * * If you have any questions, please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter. Sincerely, /s/ Michael J. Blankenship Michael J. Blankenship cc: Zhen Qin, Chief Executive Officer, Linkhome Holdings Inc.
2025-07-17 - UPLOAD - Linkhome Holdings Inc. File: 333-280379
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> July 17, 2025 Zhen Qin Chief Executive Officer Linkhome Holdings Inc. 2 Executive Circle, Suite 100 Irvine, CA 92614 Re: Linkhome Holdings Inc. Post-Effective Amendment No.5 to Form S-1 Filed June 26, 2025 File No. 333-280379 Dear Zhen Qin: We have reviewed your post-effective amendment and have the following comments. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Post-Effective Amendment No.5 on Form S-1 filed June 26, 2025 Certain Relationships and Related Party Transactions, page 80 1. Please update to provide the disclosure required by Item 404 of Regulation S-K for the three months ended March 31, 2025. Underwriting, page 92 2. We note that this offering relates to 1,250,000 shares of your common stock. We also note your disclosure here, that the underwriters are committed to purchase 2,000,000 shares. Please revise for consistency or advise. General 3. We note that Exhibit 5.1 refers to underwriter warrants that are not present in the prospectus. Please revise your legal opinion to opine on the securities being offered or advise. July 17, 2025 Page 2 We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at 202-551-3856 if you have questions regarding comments on the financial statements and related matters. Please contact Pearlyne Paulemon at 202-551-8714 or Pam Howell at 202-551-3357 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Michael J. Blankenship </TEXT> </DOCUMENT>
2025-05-13 - CORRESP - Linkhome Holdings Inc.
CORRESP 1 filename1.htm May 13, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, D.C. 20549 RE: Linkhome Holdings Inc. Post-Effective Amendment No. 3 to the Registration Statement on Form S-1, as amended Filed on April 2, 2025 File No. 333-280379 Ladies and Gentlemen: Pursuant to Rule 461 of the General Rules and Regulations under the Securities Act of 1933, as amended (the "Act"), R. F. Lafferty & Co., Inc., as the underwriter, hereby requests acceleration of the effective date of the above-referenced post-effective amendment to the registration statement so that it will become effective at effective at 4:00 p.m. Eastern Time, on May 14, 2025, or as soon thereafter as practicable. In connection with this acceleration request and pursuant to Rule 460 under the Securities Act, please be advised that there will be distributed to each underwriter or dealer, who is reasonably anticipated to be invited to participate in the distribution of the securities, as many copies, as well as "e-red" copies of the preliminary prospectus, as appears to be reasonable to secure adequate distribution of the preliminary prospectus. The undersigned advises that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. Very truly yours, R. F. Lafferty & Co., Inc. By: /s/ Robert Hackel Name: R obert Hackel Title: Chief Operating Officer
2025-05-13 - CORRESP - Linkhome Holdings Inc.
CORRESP 1 filename1.htm Linkhome Holdings Inc. 2 Executive Circle, Suite 100 Irvine, CA 92614 May 13, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, N.E. Washington, D.C. 20549 Attention: Pearlyne Paulemon and Brigitte Lippmann RE: Linkhome Holdings Inc. Post-Effective Amendment No. 3 to the Registration Statement on Form S-1, as amended Filed on April 2, 2025 File No. 333-280379 Dear Ms. Paulemon and Ms. Lippmann, Pursuant to Rule 461 of the rules and regulations promulgated under the Securities Act of 1933, as amended, Linkhome Holdings Inc. respectfully requests that the effective date of the above-referenced post-effective amendment to the Registration Statement be accelerated so as to permit it to become effective at 4:00 p.m. Washington D.C. time on May 14, 2025, or as soon thereafter as practicable. Please call Michael Blankenship of Winston & Strawn LLP at (713) 651-2678 to provide notice of the effectiveness of the post effective-amendment to the Registration Statement. Very truly yours, Linkhome Holdings Inc. By: /S/ Zhen "Bill" Qin Name: Zhen "Bill" Qin Tite: Chief Executive Officer cc: Michael Blankenship, Winston & Strawn LLP
2025-04-02 - CORRESP - Linkhome Holdings Inc.
CORRESP 1 filename1.htm April 2, 2025 BY EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, NE Washington, DC 20549 Re: Linkhome Holdings Inc. Post-Effective Amendment No. 2 to Registration Statement on Form S-1 Filed March 25, 2025 File No. 333-280379 Ladies and Gentlemen: On behalf of our client, Linkhome Holdings Inc. (the “ Company ”), we are writing to submit the Company’s response to the comments of the staff (the “ Staff ”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “ Commission ”) set forth in its letter, dated March 27, 2025, relating to the Company’s Post-Effective Amendment No. 2 to Registration Statement on Form S-1 filed via EDGAR on March 25, 2025. The Company is concurrently filing via EDGAR the Post-Effective Amendment No. 3 to Registration Statement on Form S-1 (the “ Registration Statement ”), which reflects the Company’s response to the comments received by the Staff and certain updated information. We have set forth below the comments in the Staff’s letter, in bold, and the Company’s responses thereto. Post-Effective Amendment No. 2 to Registration Statement on Form S-1 Linkhome Holdings Inc. and Subsidiary Notes to Consolidated Financial Statements Note 2 - Summary of Significant Accounting Policies New Accounting Pronouncements, page F-15 1. Regarding your adoption of ASU 2023-07 and operation as a single reportable segment, please tell us how you considered the revised disclosure requirements of ASC 280-10-50, also applying to public entities having a single reportable segment. We refer you to ASC 280-10-50-20 as revised. Response : The Company acknowledges the Staff’s comment and has revised pages F-13 and F-14 of the Registration Statement to address the Staff’s comment. * * * * * * * If you have any questions, please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter. Sincerely, /s/ Michael J. Blankenship Michael J. Blankenship cc: Zhen Qin, Chief Executive Officer, Linkhome Holdings Inc.
2025-03-28 - UPLOAD - Linkhome Holdings Inc. File: 333-280379
<DOCUMENT> <TYPE>TEXT-EXTRACT <SEQUENCE>2 <FILENAME>filename2.txt <TEXT> March 27, 2025 Zhen Qin Chief Executive Officer Linkhome Holdings Inc. 2 Executive Circle, Suite 100 Irvine, CA 92614 Re: Linkhome Holdings Inc. Post-Effective Amendment No. 2 to Registration Statement on Form S-1 Filed March 25, 2025 File No. 333-280379 Dear Zhen Qin: We have reviewed your post-effective amendment and have the following comment. Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe the comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response. After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments. Post-Effective Amendment No. 2 to Registration Statement on Form S-1 Linkhome Holdings Inc. and Subsidiary Notes to Consolidated Financial Statements Note 2 - Summary of Significant Accounting Policies New Accounting Pronouncements, page F-15 1. Regarding your adoption of ASU 2023-07 and operation as a single reportable segment, please tell us how you considered the revised disclosure requirements of ASC 280-10-50, also applying to public entities having a single reportable segment. We refer you to ASC 280-10-50-20 as revised. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. March 27, 2025 Page 2 Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at 202-551-3856 if you have questions regarding comments on the financial statements and related matters. Please contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202- 551-3713 with any other questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction cc: Michael J. Blankenship </TEXT> </DOCUMENT>
2025-03-24 - CORRESP - Linkhome Holdings Inc.
CORRESP 1 filename1.htm March 24, 2025 BY EDGAR United States Securities and Exchange Commission Division of Corporation Finance Office of Real Estate & Construction 100 F Street, NE Washington, DC 20549 Re: Linkhome Holdings Inc. Post-Effective Amendment to Registration Statement on Form S-1 Filed January 13, 2025 File No. 333-280379 Ladies and Gentlemen: On behalf of our client, Linkhome Holdings Inc. (the " Company "), we are writing to submit the Company's response to the comments of the staff (the " Staff ") of the Division of Corporation Finance of the United States Securities and Exchange Commission (the " Commission ") set forth in its letter, dated February 4, 2025, relating to the Company's Post-Effective Amendment to Registration Statement on Form S-1 filed via EDGAR on January 13, 2025. The Company is concurrently filing via EDGAR the Post-Effective Amendment No. 2 to Registration Statement on Form S-1 (the " Registration Statement "), which reflects the Company's response to the comments received by the Staff and certain updated information. We have set forth below the comments in the Staff's letter, in bold, and the Company's responses thereto. Post-Effective Amendment No. 1 to Registration Statement on Form S-1 Executive and Director Compensation, page 76 1. Please update your compensation disclosure for the fiscal year ended 2024. For guidance, see Question 117.05 of our Compliance and Disclosure Interpretations (Regulation S-K). Response : The Company acknowledges the Staff's comment and has revised pages 73 and 74 of the Registration Statement to address the Staff's comment. Exhibits 2. Please update Exhibit 5.1 to refer to R.F. Lafferty & Co., Inc. as the underwriter instead of EF Hutton LLC. Also revise the opinion in paragraphs 1 and 2 to reflect that the shares will be validly issued, fully paid and nonassessable. Finally, revise the penultimate paragraph to include the laws of the State of Nevada, as the corporation is a Nevada corporation. Response : The Company acknowledges the Staff's comment and has revised Exhibit 5.1 and added Exhibit 5.2 to address the Staff's comment. * * * * * * * If you have any questions, please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter. Sincerely, /s/ Michael J. Blankenship Michael J. Blankenship cc: Zhen Qin, Chief Executive Officer, Linkhome Holdings Inc.
2025-02-04 - UPLOAD - Linkhome Holdings Inc. File: 333-280379
February 4, 2025
Zhen Qin
Chief Executive Officer
Linkhome Holdings Inc.
2 Executive Circle, Suite 100
Irvine, CA 92614
Re:Linkhome Holdings Inc.
Post-Effective Amendment to Registration Statement on Form S-1
Filed January 13, 2025
File No. 333-280379
Dear Zhen Qin:
We have reviewed your post-effective amendment and have the following comments.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Post-Effective Amendment No. 1 to Registration Statement on Form S-1
Executive and Director Compensation, page 76
1.Please update your compensation disclosure for the fiscal year ended 2024. For
guidance, see Question 117.05 of our Compliance and Disclosure Interpretations
(Regulation S-K).
Exhibits
2.Please update Exhibit 5.1 to refer to R.F. Lafferty & Co., Inc. as the underwriter
instead of EF Hutton LLC. Also revise the opinion in paragraphs 1 and 2 to reflect
that the shares will be validly issued, fully paid and nonassessable. Finally, revise the
penultimate paragraph to include the laws of the State of Nevada, as the corporation is
a Nevada corporation.
February 4, 2025
Page 2
We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence
of action by the staff.
Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-
551-3713 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Michael J. Blankenship
2024-11-07 - CORRESP - Linkhome Holdings Inc.
CORRESP
1
filename1.htm
Linkhome Holdings Inc.
2 Executive Circle, Suite 100
Irvine, CA 92614
November 7, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549
Attention: Pearlyne Paulemon and Brigitte Lippmann
RE: Linkhome Holdings Inc.
Registration Statement on Form S-1, as amended
Filed on October 17, 2024
File No. 333-280379
Dear Ms. Paulemon and Ms. Lippmann,
Pursuant to Rule 461 of the rules and regulations promulgated under
the Securities Act of 1933, as amended, Linkhome Holdings Inc. respectfully requests that the effective date of the above-referenced Registration
Statement be accelerated so as to permit it to become effective at 4:00 p.m. Washington D.C. time on November 12, 2024, or as soon thereafter
as practicable.
Please call Michael Blankenship of Winston & Strawn LLP at (713)
651-2678 to provide notice of the effectiveness of the Registration Statement.
[Signature Page Follows]
Very truly yours,
Linkhome Holdings Inc.
By:
/s/ Zhen “Bill” Qin
Name:
Zhen “Bill” Qin
Tite:
Chief Executive Officer
cc:
Michael Blankenship, Winston & Strawn LLP
2024-11-07 - CORRESP - Linkhome Holdings Inc.
CORRESP
1
filename1.htm
DAWSON JAMES SECURITIES INC.
101 North Federal Highway
Suite 600
Boca Raton, Fl 33432
November 7, 2024
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, N.E.
Washington, D.C. 20549
RE: Linkhome Holdings Inc.
Registration Statement on Form S-1, as amended
Filed on October 17, 2024
File No. 333-280379
Ladies and Gentlemen:
Pursuant to Rule 461 of
the General Rules and Regulations under the Securities Act of 1933, as amended (the “Act”), the undersigned, for itself and
the other underwriters, hereby join in the request of Linkhome Holdings Inc. that the effective date of the above-referenced registration
statement be accelerated so as to permit it to become effective at 4 p.m., Eastern Time, on November 12, 2024 or as soon thereafter as
practicable.
Pursuant to 460 under the
Act, we wish to advise you that the underwriters will distribute as many copies of the preliminary prospectus dated October 17, 2024 to
underwriters, dealers, institutions and others as appears to be reasonable to secure adequate distribution of such preliminary prospectus.
The undersigned advises
that it has complied and will continue to comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
Very truly yours,
DAWSON JAMES SECURITIES INC.
By:
/s/ Robert D. Keyser, Jr.
Name:
Robert D. Keyser, Jr.
Title:
Chief Executive Officer
2024-10-17 - CORRESP - Linkhome Holdings Inc.
CORRESP
1
filename1.htm
October 17, 2024
BY EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, NE
Washington, DC 20549
Re:
Linkhome Holdings Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed October 1, 2024
File No. 333-280379
Ladies and Gentlemen:
On behalf of our client, Linkhome
Holdings Inc. (the “Company”), we are writing to submit the Company’s response to the comments of the staff (the
“Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”)
set forth in its letter, dated October 16, 2024, relating to the Company’s Amendment No. 3 to Registration Statement on Form S-1
filed via EDGAR on October 1, 2024.
The Company is concurrently
filing via EDGAR the Amendment No. 4 to Registration Statement on Form S-1 (the “Registration Statement”), which reflects
the Company’s response to the comments received by the Staff and certain updated information.
We have set forth below the
comments in the Staff’s letter, in bold, and the Company’s responses thereto.
Form S-1/A3 filed October 1, 2024
Item 16. Exhibits and Financial
Statement Schedules, page II-3
1.
We note your disclosure on page F-19 that the company entered into a stock subscription agreement with one of the existing shareholders. Please describe these transactions, as required by Item 404(d)(1) of Regulation S-K or advise. Also file these agreements as exhibits. See Item 601(b)(10) of Regulation S-K.
Response: The Company acknowledges
the Staff’s comment and has revised page F-19 of the Registration Statement to address the Staff’s comment. A form of the
stock subscription agreement has previously been filed as Exhibit 10.6.
General
2.
Please file your final signed legal opinion as Exhibit 5.1.
Response: The Company acknowledges
the Staff’s comment and has filed the final signed legal opinion as Exhibit 5.1.
* * * * * * *
If you have any questions,
please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter.
Sincerely,
/s/ Michael J. Blankenship
Michael J. Blankenship
cc:
Zhen Qin, Chief Executive Officer, Linkhome Holdings Inc.
2024-10-16 - UPLOAD - Linkhome Holdings Inc. File: 377-07179
October 16, 2024
Zhen Qin
Chief Executive Officer
Linkhome Holdings Inc.
2 Executive Circle, Suite 100
Irvine, CA 92614
Re:Linkhome Holdings Inc.
Amendment No. 3 to Registration Statement on Form S-1
Filed October 1, 2024
File No. 333-280379
Dear Zhen Qin:
We have reviewed your amended registration statement and have the following
comments.
Please respond to this letter by amending your registration statement and providing
the requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
After reviewing any amendment to your registration statement and the information
you provide in response to this letter, we may have additional comments.
Amendment No.3 to Registration Statement on Form S-1
Item 16. Exhibits and Financial Statement Schedules, page II-3
1.We note your disclosure on page F-19 that the company entered into a
stock subscription agreement with one of the existing shareholders. Please describe
these transactions, as required by Item 404(d)(1) of Regulation S-K or advise. Also
file these agreements as exhibits. See Item 601(b)(10) of Regulation S-K.
General
2.Please file your final signed legal opinion as Exhibit 5.1.
October 16, 2024
Page 2
Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related
matters. Please contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-
551-3713 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Michael J. Blankenship
2024-07-19 - CORRESP - Linkhome Holdings Inc.
CORRESP
1
filename1.htm
July 19, 2024
BY EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, NE
Washington, DC 20549
Re:
Linkhome Holdings Inc.
Amendment No. 1 to Registration Statement on Form S-1
Filed July 10, 2024
File No. 333-280379
Ladies and Gentlemen:
On behalf of our client, Linkhome
Holdings Inc. (the “Company”), we are writing to submit the Company’s response to the comments of the staff (the
“Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”)
set forth in its letter, dated July 19, 2024, relating to the Company’s Amendment No. 1 to Registration Statement on Form S-1 filed
via EDGAR on July 10, 2024.
The Company is concurrently
filing via EDGAR the Amendment No. 2 to Registration Statement on Form S-1 (the “Registration Statement”), which reflects
the Company’s response to the comments received by the Staff and certain updated information.
We have set forth below the
comments in the Staff’s letter, in bold, and the Company’s responses thereto.
Form S-1/A filed July 10, 2024
Principal Stockholders, page 80
1.
We note your response to prior comment 1. Please include all three executive officers and your three director nominees in the table. See Item 403(b) of Regulation S-K. Also revise the footnotes to the table for consistency.
Response: The Company acknowledges
the Staff’s comment and has revised page 80 of the Registration Statement to address the Staff’s comment.
* * * * * * *
If you have any questions,
please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter.
Sincerely,
/s/ Michael J. Blankenship
Michael J. Blankenship
cc:
Zhen Qin, Chief Executive Officer, Linkhome Holdings Inc.
2024-07-19 - UPLOAD - Linkhome Holdings Inc. File: 377-07179
July 19, 2024
Zhen Qin
Chief Executive Officer
Linkhome Holdings Inc.
2 Executive Circle, Suite 100
Irvine, CA 92614
Re:Linkhome Holdings Inc.
Amendment No.1 to Registration Statement on Form S-1
Filed July 10, 2024
File No. 333-280379
Dear Zhen Qin:
We have reviewed your amended registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe the comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we note otherwise,
any references to prior comments are to comments in our July 3, 2024 letter.
Form S-1/A filed July 10, 2024
Principal Stockholders, page 80
1.We note your response to prior comment 1. Please include all three executive officers and
your three director nominees in the table. See Item 403(b) of Regulation S-K. Also revise
the footnotes to the table for consistency.
July 19, 2024
Page 2
Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Michael J. Blankenship
2024-07-10 - CORRESP - Linkhome Holdings Inc.
CORRESP
1
filename1.htm
July 10, 2024
BY EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, NE
Washington, DC 20549
Re:
Linkhome Holdings Inc.
Registration Statement on Form S-1
Filed June 21, 2024
File No. 333-280379
Ladies and Gentlemen:
On behalf of our client, Linkhome
Holdings Inc. (the “Company”), we are writing to submit the Company’s response to the comments of the staff (the
“Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”)
set forth in its letter, dated July 3, 2024, relating to the Company’s Registration Statement on Form S-1 filed via EDGAR on June
21, 2024.
The Company is concurrently
filing via EDGAR the Registration Statement on Form S-1 (the “Registration Statement”), which reflects the Company’s
response to the comments received by the Staff and certain updated information.
We have set forth below the
comments in the Staff’s letter, in bold, and the Company’s responses thereto.
Form S-1 Submitted June 21, 2024
Principal Stockholders, page 80
1.
We note your response to prior comment 5. Unless your greater than 5% stockholder is an officer or director of the company, it is unclear why the address is the same as the company's address. Please revise or advise.
Response: The Company acknowledges
the Staff’s comment and has revised page 80 of the Registration Statement to address the Staff’s comment.
* * * * * * *
If you have any questions,
please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter.
Sincerely,
/s/ Michael J. Blankenship
Michael J. Blankenship
cc:
Zhen Qin, Chief Executive Officer, Linkhome Holdings Inc.
2024-07-03 - UPLOAD - Linkhome Holdings Inc. File: 377-07179
July 3, 2024
Zhen Qin
Chief Executive Officer
Linkhome Holdings Inc.
2 Executive Circle, Suite 100
Irvine, CA 92614
Re:Linkhome Holdings Inc.
Registration Statement on Form S-1
Filed June 21, 2024
File No. 333-280379
Dear Zhen Qin:
We have reviewed your registration statement and have the following comment.
Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe the comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Form S-1
Principal Stockholders, page 80
1.We note your response to prior comment 5. Unless your greater than 5% stockholder is an
officer or director of the company, it is unclear why the address is the same as the
company's address. Please revise or advise.
We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of action
by the staff.
Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
July 3, 2024
Page 2
Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:Michael J. Blankenship
2024-06-21 - CORRESP - Linkhome Holdings Inc.
CORRESP
1
filename1.htm
June 21, 2024
BY EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
Office of Real Estate & Construction
100 F Street, NE
Washington, DC 20549
Re:
Linkhome Holdings Inc.
Amendment No. 1 to Draft Registration Statement
on Form S-1
Submitted May 29, 2024
CIK No. 0002017758
Ladies and Gentlemen:
On behalf of our client, Linkhome
Holdings Inc. (the “Company”), we are writing to submit the Company’s response to the comments of the staff (the
“Staff”) of the Division of Corporation Finance of the United States Securities and Exchange Commission (the “Commission”)
set forth in its letter, dated June 11, 2024, relating to the Company’s Amendment No. 1 to Draft Registration Statement on Form
S-1 filed via EDGAR on May 29, 2024.
The Company is
concurrently filing via EDGAR the Registration Statement on Form S-1 (the “Registration Statement”), which
reflects the Company’s response to the comments received by the Staff and certain updated information.
We have set forth below the
comments in the Staff’s letter, in bold, and the Company’s responses thereto.
Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted
May 29, 2024
Prospectus Summary, page 1
1.
We note your response to prior comment 1. However, you still have not disclosed the source for your claim that you are "one of the fastest-growing artificial intelligence real estate platforms in the United States." Identify the two competing real estate platforms which are developing their own AI tools. Balance your discussion of revenue growth with your net income growth. Also update your market data, such as the 2020 NAR data, throughout the filing to the latest available date.
Response: The Company acknowledges the Staff’s comment and has supplemented
the Prospectus Summary disclosures and pages 1, 2 and 62 of the Registration Statement to address the Staff’s Comment.
2.
We note your response to prior comment 2. Please clarify that the transaction with the Cash Offer tool was with a related party, a beneficial owner of 12.5% of your voting securities.
Response: The Company acknowledges the Staff’s comment and has supplemented
the Prospectus Summary disclosures and page 1 of the Registration Statement to address the Staff’s Comment.
Management’s Discussion and Analysis of Financial Condition
and Results of Operations Selected Income Statement Items Total Revenues, page 46
3.
We note your response to our prior comment 4 and revised disclosure here explaining the decline in real estate agency commission revenues from fiscal 2022 to fiscal 2023 as a function of the lower real estate transaction dollar volume of $15,438,435 in 2023 as compared to $28,243,875 in 2022. However, these amounts are disclosed in reverse order for each year on pages 1 and 62. Please revise.
Response: The Company acknowledges the Staff’s comment and has revised
pages 1 and 62 of the Registration Statement to address the Staff’s comment.
Certain Relationships and Related-Party
Transactions, page 79
4.
We note your response to prior comment 6. Please disclose the names of the related parties for each transaction. See Item 404(a)(1) of Regulation S-K.
Response: The Company acknowledges the Staff’s comment and has revised
pages 44 and 79 of the Registration Statement to address the Staff’s comment.
Principal Stockholders, page 80
5.
Please disclose the address of your greater than five percent beneficial owner. See Item 403(a) of Regulation S-K.
Response: The Company acknowledges the Staff’s comment and has revised
page 80 of the Registration Statement to address the Staff’s comment.
General
6.
Please file the consent of each director nominee as an exhibit to your registration statement. See Securities Act Rule 438.
Response The Company acknowledges
the Staff’s comment and has filed the consent of each director as Exhibit 99.1 – 99.5 to address the Staff’s Comment.
* * * * * * *
2
If you have any questions,
please feel free to contact me at (713) 651-2678. Thank you for your cooperation and prompt attention to this matter.
Sincerely,
/s/ Michael J. Blankenship
Michael J. Blankenship
cc:
Zhen Qin, Chief Executive Officer, Linkhome Holdings Inc.
3
2024-06-11 - UPLOAD - Linkhome Holdings Inc. File: 377-07179
United States securities and exchange commission logo
June 11, 2024
Zhen Qin
Chief Executive Officer
Linkhome Holdings Inc.
2 Executive Circle, Suite 100
Irvine, CA 92614
Re:Linkhome Holdings Inc.
Amendment No. 1 to Draft Registration Statement on Form S-1
Submitted May 29, 2024
CIK No. 0002017758
Dear Zhen Qin:
We have reviewed your amended draft registration statement and have the following
comments.
Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
May 7, 2024 letter.
Amendment No. 1 to Draft Registration Statement on Form S-1 Submitted May 29, 2024
Prospectus Summary, page 1
1.We note your response to prior comment 1. However, you still have not disclosed the
source for your claim that you are "one of the fastest-growing artificial intelligence real
estate platforms in the United States." Identify the two competing real estate platforms
which are developing their own AI tools. Balance your discussion of revenue growth with
your net income growth. Also update your market data, such as the 2020 NAR data,
throughout the filing to the latest available date.
2.We note your response to prior comment 2. Please clarify that the transaction with the
Cash Offer tool was with a related party, a beneficial owner of 12.5% of your voting
securities.
FirstName LastNameZhen Qin
Comapany NameLinkhome Holdings Inc.
June 11, 2024 Page 2
FirstName LastName
Zhen Qin
Linkhome Holdings Inc.
June 11, 2024
Page 2
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Selected Income Statement Items
Total Revenues, page 46
3.We note your response to our prior comment 4 and revised disclosure here explaining the
decline in real estate agency commission revenues from fiscal 2022 to fiscal 2023 as a
function of the lower real estate transaction dollar volume of $15,438,435 in 2023 as
compared to $28,243,875 in 2022. However, these amounts are disclosed in reverse order
for each year on pages 1 and 62. Please revise.
Certain Relationships and Related-Party Transactions, page 79
4.We note your response to prior comment 6. Please disclose the names of the related
parties for each transaction. See Item 404(a)(1) of Regulation S-K.
Principal Stockholders, page 80
5.Please disclose the address of your greater than five percent beneficial owner. See Item
403(a) of Regulation S-K.
General
6.Please file the consent of each director nominee as an exhibit to your registration
statement. See Securities Act Rule 438.
Please contact Frank Knapp at 202-551-3805 or Shannon Menjivar at 202-551-3856 if
you have questions regarding comments on the financial statements and related matters. Please
contact Pearlyne Paulemon at 202-551-8714 or Brigitte Lippmann at 202-551-3713 with any
other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc: Michael J. Blankenship